Surely if you declare compliance with any particular Directive on your Declaration then you must follow the attestation procedures for that Directive. On the basis of a quick look, there is no attestation route under the NAWID which does not require some form of Notified Body intervention. I know that this is not completely true for the MID, but in practice most measuring instruments do require NB intervention for CE marking under the MID.
Therefore, it seems to me that unless you engage an NB to help you declare compliance for your complete machine, you cannot include a declaration of compliance to the NWAID or the MID on the Declaration of the complete machine. The Machinery Directive says that you also need to identify any other applicable Directives on your Declaration: "a sentence expressly declaring that the machinery fulfils all the relevant provisions of this Directive and where appropriate, a similar sentence declaring the conformity with other Directives and/or relevant provisions with which the machinery complies.” (2006/42/EC annex II (1 )A item 4). A strict reading of this means you have to declare compliance with the NWAID in addition to the Machienry Directive, but applying my logic above that would imply involving an NB to be involved in attestation of the complete machine, something I’m sure you won’t want to do. My advice is to issue a Declaration in which you claim compliance only for those Directives where you have competed the correct attestation procedure (likely to be Machinery, EMC and RoHS in this case) and supply a copy of the weighing machine’s DofC alongside your machinery DofC. If you attempt to ‘badge' the weighing machine as your own by not supplying the OEM’s Declaration then I think you will need to comply with the NWAID and/or the MID which means applying the relevant procedures from these directives. Nick. > On 16 Jan 2015, at 18:13, Nyffenegger, Dave <dave.nyffeneg...@bhemail.com> > wrote: > > Hi folks, > > I design and manufacture light machinery that includes some sub-assemblies > which we purchase and integrate. The sub-assemblies come with their own DoI. > In particular I may integrate automatic and non-automatic weighing scales > that would come with a DoI or DoC for the machinery and directive and a DoC > or DoI for the EMC, 2004/22/EC Measuring Instruments, and 2009/23/EC > Non-automatic Weighing Instruments directives. I do not modify the weighing > functionality of the scales nor do I do any additional certification on them. > > The metrology directives require special marking, the CE mark as well as the > "M" mark and notified body ID which come already on the units I integrate. > > There are no weighing devices that I directly manufacturer that are part of > the machinery. What I'm not clear on is whether I should claim compliance to > the 2004/22/EC Measuring Instruments and 2009/23/EC Non-automatic Weighing > Instruments directives on my DoC and/or product nameplate for the complete > machine or whether I should just include the OEM's DoC along with my DoC in > the paperwork supplied with the machine (and technical file). > > I don't know if this situation is different than any are CE marked component > within the machine but it would seem so. The EU directives do not actually > apply directly to many components that the OEM marks and claims compliance to > CE to make it easier for system builders like me. (Some actually state that > on their DoCs). The Metrology directives are specific to the scales. > > Does anyone have any experience with this or something similar? > > thanks > > David P. Nyffenegger, PMP, SM-IEEE > Product Development Manager > - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
